Privacy Notice

WHAT IS THIS?

When you deal with Juristrust, you trust us with your information. We take privacy seriously and we are committed to protecting the data you provide to us.

This notice explains when and why we collect personal data about you, how it is used, the conditions under which it may be disclosed to others and how it is kept secure.

This notice may change from time to time so please re-visit this page occasionally to ensure that you are happy with any changes.

WHO ARE WE?

Juristrust Limited is licensed by the Isle of Man Financial Services Authority and is a company registered in the Isle of Man with registered number 126025C. Its registered office is Ridgeway House, Ridgeway Street, Douglas, Isle of Man IM99 1PY.

References in this notice to:

“Juristrust” or “we” or “our” or “us” shall mean Juristrust Limited; and

“You” or “your” shall mean the user of this website. If you are accessing or using this website in your capacity as an employee, director, officer, partner or agent of a corporate or unincorporated entity “”you” and “your” shall refer to you and such entity.

Juristrust is the controller of your personal data when you engage it to provide services to you. This means that Juristrust decides why and how your personal data is processed.

PERSONAL DATA THAT WE HOLD AND HOW WE COLLECT YOUR PERSONAL DATA

The information we hold about you consists of all the personal data, financial data and in certain circumstances sensitive or special categories of personal data (hereinafter referred to as “personal data/information”) we hold about you. It includes:

Information we receive about you from you or third parties when we are acting for a client and we are required to obtain information about you, for example if you are a beneficiary of a trust or a director of a company. The information we receive may include your contact details, identification information, financial information, employment information and details included in any correspondence and information about you in connection with any matter on which we are engaged to provide services to our client (including biographical and personal/circumstantial details).

Information you give us:

• When you make an enquiry to Juristrust, or engage us to provide trust and/or corporate services to you
• Information we learn about you through our engagement with you
• Information that you provide by accessing and using our website, we may also ask you for information when you report a problem with our website
• If you contact us by fax, email or letter we may keep a record of that correspondence.
• The information you give us mainly includes your contact details, identification information, financial or billing information, employment information and details included in any correspondence and information about you in connection with any matter on which we are engaged to advise you (including biographical and personal/circumstantial details).

Information we receive from third parties:

(Including credit reference agencies, government departments, experts we engage, or other third parties who provide services to you or us)

• For example in transactional matters from law firms, accountants and other professional advisors acting for you where our client is a party to or otherwise concerned in the course of the transaction
• For example in dispute resolution matters from law firms, counsel, experts and professional advisors acting for you or for us on your behalf or from third parties where our client is a party to or otherwise concerned, for example in mediation, potential or actual litigation
• For example from banks, building societies and finance companies, where you are their customer, or who are clients of ours or from whom we are given or request information
• For example in relation to clients acting in a representative capacity such as personal representatives, attorneys or trustees who may provide us with information in connection with a matter, for example about a beneficiary of an estate or a trust
• Such as employers who may provide us with a reference on you
• Such as court officers
• Such as police making enquiries into potential criminal offences
• Such as regulatory bodies when making regulatory enquiries
• Information that we gather from publicly available sources.
• In respect of any personal information relating to a third party, you warrant that you can lawfully share personal data relating to such third party with us and to the best of your knowledge, the personal information is accurate and up to date and you will promptly notify us if you become aware that it is incorrect.

TYPES OF PERSONAL DATA WE PROCESS ABOUT YOU

We may process a range of data about you. We have divided the information into categories as follows, although not all categories may be applicable to you:

Category	Personal data included in this category
Banking/billing	Information used to send/receive funds to/from you or that appears on your bills
Cardholder	Your payment card details
Contact	Information which can be used to address, send or otherwise communicate a message to you (e.g. email address, postal address, employer name and job title)
Correspondence	Information contained in our correspondence or other communications with you or about you, about our services or business
Employment	Your previous, current or future employment details
Identification	Information contained in a formal identification document or social security or other unique reference relating to you
Monitoring	If you visit our offices your image may be recorded on CCTV for security purposes

HOW AND WHY WE USE YOUR PERSONAL DATA

We may use the information that we collect about you in the following ways:

• Where it is necessary for us to perform a contract with you
• We may use and process your personal data where we have supplied you or continue to supply you with any services, where we have arranged for the supply of another firm’s services to you, or where we are in discussions with you about a particular matter on which you are considering taking advice.
• We may also use and process your personal data in connection with our recruitment activities, if you apply for a position with us or send your details to us on a speculative basis.
• Where we have a legitimate interest

We may use and share your personal data/information within Juristrust to:

• Undertake and clear conflicts checks in connection with the provision of services
• assist with our file opening and file management process
• Enter into or perform the contract we have with your business
• Manage our relationship with you
• Understand your expectations in order to improve the service we provide to you
• Develop, test and monitor our services, internal systems and security arrangements
• Assess the quality of our service to clients and to provide staff training
• Recover debt
• Confirm your identity
• Prevent and detect crime, including fraud, money laundering and bribery offences
• Comply with legal and regulatory obligations
• Comply with a request from you in connection with the exercise of your rights (for example a subject access request)
• To assist with the management of queries, complaints or claims
• For the establishment, exercise or defence of our legal rights.

Where you have provided consent we may need to use more sensitive personal data (known as special categories of personal data) about you or others associated with you, we will only use this kind of information where we have your explicit consent. Where you have provided your explicit consent to the use of special categories of personal data about you, you may withdraw your consent for us to use this information at any time. Where you have given us your consent, we will use and process your personal data to send you email communications about events, products and news updates and relevant news and announcements.  Such communications may include content on relevant legal updates, seminar and event invitations and other news/announcements.

HOW LONG WE WILL KEEP YOUR PERSONAL DATA

If we collect your personal data, the length of time for which we retain it is determined by a number of factors including the type of data, the purpose for which we use the data and our legal and regulatory obligations attached to this use. We don’t retain personal data in an identifiable format for longer than is necessary. We maintain internally a full schedule of types of data and the specified periods of time we will retain this for.

Typically, following conclusion of our engagement, we will store files and their contents electronically, with back up, for not less than six years. However personal data will be retained for as long as it is required by us in order to comply with our legal and regulatory requirements, or for legitimate interest reasons.   Destruction of the personal data/information will be completed as soon as practicable thereafter.  After expiry of that period the storage media may be erased without further reference to you, unless you have previously asked us in writing to keep them for longer and we have reached specific agreement with you about this. We reserve the right to charge a reasonable fee for the production of documents stored by us. We are entitled to keep all or any such papers, documents and correspondence without releasing copies to you whilst there is money owing to us for our fees and disbursements.

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL DATA

We may use and share your personal data/information with third parties:

• Where we have your permission
• Who are our suppliers and service providers
• Where required in order for us to carry out our contractual obligations as detailed in our letter of engagement/email engagement
• Where we are required to by law, to law enforcement agencies, government entities, tax authorities or regulatory bodies
• Where third parties are providing services to us in connection with your managed or related entities such as banks, accountants, lawyers and other agents and sub-contractors acting on our behalf
• Such as credit reference and fraud prevention agencies for the purposes of our client due diligence procedures
• Credit / debit card payment processors
• Where reasonably required for a sale, reorganisation, transfer or other transaction relating to our business
• In anonymised form as part of statistics or other aggregated data shared with third parties
• Where permitted by law, it is necessary for our legitimate interests or those of a third party and is not inconsistent with the purposes listed above.

We will not share your information with third parties for marketing purposes. All information you provide to us is stored on our secure servers which are located within the Isle of Man and the EEA.  We may transfer your personal data/information to organisations in other countries on the basis that (i) anyone to whom we pass it protects it in substantially the same way we would and in accordance with applicable laws or (ii) you expressly consent to the transfer of your personal data and information to the organisation concerned.

YOUR RIGHTS

Juristrust has not appointed a data protection officer. Data protection queries can be emailed to enquiries@juristrust.im or can be addressed by letter and posted to the Board of Directors, Juristrust Limited, Ridgeway House, Ridgeway Street, Douglas, Isle of Man, IM1 1EL. You have the following rights under data protection legislation:

A right to access your personal data. A request should be made by emailing enquiries@juristrust.im.    We will respond to requests to provide copies of the personal data held by us within the prescribed timeframe.  We may not provide you with a copy of your personal data if it concerns other individuals or if we have another lawful reason to withhold that data;

A right to have any inaccurate data corrected. If you believe that any of the information that we hold about you is inaccurate, or if you have any queries about how we use your personal data which are not answered here, please contact us by emailing enquiries@juristrust.im;

The right to request that we stop processing your personal data for marketing purposes – if you have permitted us to do so, then we’ll send you relevant marketing information. If you change your mind and you no longer wish to receive this information, you can tell us at any time by emailing enquiries@jursitrust.im;

You have the right to have the personal data that we hold about you destroyed, subject to certain restrictions;

You have the right to lodge a complaint with us in relation to the processing of your personal data. If the matter has not been resolved satisfactorily you may complain to the Isle of Man Information Commissioner.

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we’ll notify you and will allow a period of 30 days for you to raise any objections before the change is made. However please note, in some cases, if you don’t agree to such changes it may not be possible for us to continue to act for you.

We also draw your attention to any additional information relating to how we may use your personal data as contained in our letter of engagement/fee agreement and terms of business addressed to you.

We reserve the right to vary and amend this Notice from time to time. Any changes shall take effect upon posting to this website.

Any dispute arising between you and Juristrust in relation to this website shall be governed by Isle of Man law and you submit to the exclusive jurisdiction of the Isle of Man Courts for the purposes of any such dispute.